39 0 obj <>/Filter/FlateDecode/ID[<3DE8017F54D98D5939ED3FFC60811FA0><341CF33D3F5EAB49B7E5710A1889DF18>]/Index[30 26]/Info 29 0 R/Length 62/Prev 47862/Root 31 0 R/Size 56/Type/XRef/W[1 2 1]>>stream SUPERIOR COURT OF NEW JERSEY. State your full name, home address, business address, and occupation. uuid:984c0652-48fa-4f55-badd-b9b174a742c7 Too many lawyers spend a lot of energy drafting great questions only to fall asleep when the defendant provides inadequate answers. Form C. Uniform Interrogatories to be Answered by Defendant in All Personal Injury Cases: Superior Court. If you are unable to answer an interrogatory fully, submit as much information as is available, explain why your answer is incomplete, and identify or describe all other sources of more complete or accurate information. Employer Notice of Workers' Compensation Insurance Coverage:this link will take you to the NJ Compensation Rating & Inspection Bureau's website. 17. Get a copy to your clients quickly. Interrogatories-Limited Civil Cases (Economic Litigation) (form DISC-004)) in the same action. SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. Attorneys hate taking positions before trial. Questions About Marriage and Marital History. 1. The form must be signed by the firm's Contact Person prior to submitting. A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT. Follow instructions on the form. 3. But please read the interrogatories carefully and make sure they fit your case. Pursuant to Fed. Ask defendants the hard questions and ask them early in the case to pin them down (and to have time to file a motion to compel when they don't give complete answers). Unless otherwise specified, the information called for by these interrogatories is limited in scope to information relating to supplying, manufacturing, distributing, selling, or advertising or promoting products in the United States. CN: 10159. When practicing family law here in New Jersey, one of the most fact sensitive areas for an attorney to handle is a child custody case. A-5298-07T25298-07T2. It can be either in the form of a question (usually contention interrogatories), or they can direct the answering party to supply accurate information that is described. Limitation of Interrogatories. 7. 1 0 obj responses to first set of interrogatories ELECTRONICALLY FILED - 2018 Mar 15 2:01 PM - GREENVILLE - COMMON PLEAS - CASE#2014CP2304432. "Identify" or "identity" means to state or a statement of: a. in the case of a person other than a natural person, its name, the address of its principal place of business (including zipcode), its telephone number, and the name of its chief executive officer, as well as, if it has a person other than a natural person that ultimately controls it, that other person's name, the address of that person's principal place of business (including zipcode), that other person's telephone number, and the name of that other person's chief executive officer; b. in the case of a natural person, his or her name, business address and telephone number, employer, and title or position; c. in the case of a communication, its date, type (e.g., telephone conversation or discussion), the place where it occurred, the identity of the person who made the communication, the identity of the person who received the communication, the identity of each other person when it was made, and the subject matter discussed; d. in the case of a document, the title of the document, the author, the title or position of the author, the addressee, each recipient, the type of document, the subject matter, the date of preparation, and its number of pages; and. The interrogatories shall be so arranged that after each separate question shall appear a blank space reasonably calculated to enable the answering party to have the answer typed in. %PDF-1.3 % at [email protected] or call him toll-free at (855) 376-5291. In the sample above, the first set listed assumes that all 30 interrogatories are asked at one time. Then draft your discovery and demand answers that fairly and honestly answer the questions. Resource Family Information Form. Search for another form here. (fillable), Order Approving Settlement under NJSA 34:15-20:(fillable) (page 1 and 2), Order for Distribution (for child support), Order for Distribution of Temporary Award (for child support), Affidavit of Dependent in Support of Settlement Under N.J.S.A. 0000003987 00000 n The biggest mistake plaintiffs' personal injury lawyers make after serving interrogatories is not demanding complete answers. Because the number of requests is restricted without a court order or an agreement among the parties, interrogatories in a complex case should be carefully drafted to request only information that a lawyer cannot find using other discovery mechanisms. INTERROGATORIES RELATING TO JURISDICTIONAL DISCOVERY Pursuant to Rule 33 of the Federal Rules of Civil Procedure, Smithfield Foods, Inc. ("SFD") states its responses and objections to Plaintiff's First Set of Interrogatories Relating to Jurisdictional Discovery ("Interrogatories") as follows: GENERAL OBJECTIONS 1. "Document" means any written, recorded, or graphic material of any kind, whether prepared by you or by any other person, that is in your possession, custody, or control. Pursuant to Fed. 4!mU>]3Nn6~p ,5_Rn]`R.nQirvuA+`i&.8ZfS |cg2'~pY>+8u4>)n9wv|aS9)y>P4}/fd`0W2bUOg"~yf;+[?JZjbtt5qr'r4"|D>fYLZCCE+zX9/+3qyq#1$x,8U1UBV(hSwa3>"n.$2=b. 0000007135 00000 n 1. In 1994, Maryland Rule 2-421 was amended to allow a party to serve more than a single set of interrogatories. In most jurisdictions, parties may serve 30 written questions. These questions are referred to as "Interrogatories". endobj See, R. 4:17-4(a). Focusing just on this is better than reading a thousand different articles on developing discovery. The case settled and I got a lot more money than I expected. State your full name, your present address, and date of birth. If you believe your employer decided against promoting you because of a discriminatory reason, you should talk to the attorneys at Swartz Swidler. Objections made thereafter shall not be entertained by the court. Directory of Superior Court Deputy Clerk's Offices/County Lawyer Referral and Legal Services Offices. 0000002957 00000 n 2 0 obj Case Management Order. Insurance defense counsel often refuses to answer discovery. Second Injury Fund Information Review Sheet(fillable), Judgment / Order Approving Settlement(fillable) (with Case Exhibit Listing), Generic Order (for Miscellaneous Decisions, Motions, etc.) 0000056111 00000 n On appeal from Superior Court of New Jersey, Law Division, Union County, Docket No. 0000002626 00000 n Washington, DC 20005 . Insurance Carrier / Self-Insurer Contact Listing: these individuals can be contacted by judicial staff and attorneys where there has been no appearance or formal response made by the carrier or their counsel on pending Motions for Medical and Temporary Benefits. If a party denies a request for admission that goes to a critical component of Plaintiff's personal injury case, an alternative interrogatory asks the defendant to set forth all facts and evidence upon which the defendant intends to rely upon at trial to support the defense lawyer's denial. 8/9/97 1. SUPERIOR COURT OF NEW JERSEY CHANCERY DIVISION - ESSEX VICINAGE 0000001829 00000 n (c) In response to any interrogatory, you are permitted to provide copies of business "Dealer" means any person that distributes any dental products of any other person or purchases or acquires any such product for the sole purpose of reselling such products to any other person, such as a dental laboratory, dentist, dental school or government entity. You must answer each interrogatory separately and fully in writing under oath, unless you believe there is a legal reason not to answer it (if you object to it). Interrogatories are written questions answered under oath. We like to draft some of the answers for them based on their responses to our questionnaire and other information we have, and the clients fill in the blanks. Pursuant to Tennessee Rule of Civil Procedure 26.02(5), if any *266 Mr. David A. Rappeport, attorney for plaintiff. Service, Scope of Interrogatories (a) Generally. "Communication" means any disclosure, transfer, or exchange of information or opinion, however made. 2. They quite literally worked as hard as if not harder than the doctors to save our lives. 0000000951 00000 n They also object because a particular word is not defined (no matter what the word is, right down to question what the definition of "is" is). CERTIFICATE OF SERVICE. So both the client and the lawyer are usually involved in preparing these written responses. Think about the case individually. APPELLATE DIVISION. Service, Scope of Interrogatories, Rule 4:17-2. Decided February 14, 1963. % 5. NEW JERSEY'S CIVIL COURT PROCEDURES UPDATED AS OF JANUARY 2011 NEW JERSEY INSTITUTE OF CONTINUING LEGAL EDUCATION One Constitution Square, New Brunswick, N.J. 08901-1520 (732) 249-5100 The New Jersey Institute for Continuing Legal Education Celebrating over 40 years of service to the bench and bar Plaintiff requests that Defendant serve its answers, in writing and under oath, to the undersigned counsel for Plaintiff at 325 Seventh Street, N.W., Room 400, Washington, D.C. 20530, within 30 days of service of these Interrogatories. 15. {i;6#0O R(VnxTw&:f0L(Y#c{l'tD C]FqC eZ yvm?6=a/DFdrz3 }*S B4,;B@+D\M.F6``CnFwg8#k7"K3T$222LU4iY6@U@pTnb!]1?=g4spG0 `>X=bkKw#>LPb"; No matter what the objection, the key is to object quickly and press the defendant with a motion to compel if necessary. You know you have written a poor answer if a juror rolls their eyes when the question and answer are read in court. The list below contains the sample NJ divorce documents discussed above. 4 0 obj For any record or document responsive or relating to these interrogatories which is known to have been destroyed or lost, or is otherwise unavailable, identify each such document by author, addressee, date, number of pages, and subject matter; and explain in detail the events leading to the destruction or loss, or the reason for the unavailability of such document. I, I, XXX certify that on this 29th day of the month of October, 2009. Privilege Log. Form, Service and Time of Answers, Rule 4:17-5. Part VII offers additional Model Discovery. Just think about what you are trying to prove at trial and explore those issues. 4. This Standard Document has integrated notes with important explanations and drafting tips for the caption, introduction, signature block, definitions, instructions, specific interrogatories, and answering party's form certification. 0000001288 00000 n The user is on notice that neither the State of NJ site nor its operators review any of the services, information and/or content from anything that may be linked to the State of NJ site for any reason. R. Civ. We have a number of samples in all different types of tort cases above. Subpoena to Produce Documents, Information, or Objections or to Permit Inspection of Premises (AO 88b) Category: Civil. State: (a) the full name and residence address of each defendant . Employee's Claim Petition(can be used for Amended CP), Employee's Claim Petition Supplemental Page, Application for Review or Modification of Formal Award (can be used for Amended ReOpener), Dependency Claim Petition(can be used for Amended DCP), Dependency Claim Petition To Convert Voluntary Tender to Formal Judgment, Notice of Motion for Temporary and/or Medical Benefits(fillable), Standard petitioner's occupational interrogatory form, Second Injury Fund Verified Petition(fillable), Medical Provider Application for Payment or Reimbursement of Medical Payment, Uninsured Employer's Fund Information Packet, Respondent's Answer to Claim Petition (can be used for Amended Answer), Respondent's Answer to Application for Review & Modification of Formal Award (can be used for Amended Answer), Respondent's Answer to Dependency Claim Petition, Answering Statement for Motion for Medical and/or Temporary Benefits(fillable), Respondent's Answer to Medical Claim Petition, Standard respondent's occupational interrogatory form, Request for Adjournment / Ready Hold - page 1 (fillable). Below are samples of interrogatories we have received from common defendants in tort cases, such as insurance carriers. Uniform Interrogatories in New Jersey Rule 4 :17-1(b)(2) Cases > > Read More.. Drafting Interrogatories to Support a Fraud Claim by Practical Law Commercial Litigation Maintained USA (National/Federal) A Practice Note explaining the basic considerations for counsel drafting interrogatories to support a common law fraud claim under state law. Ans. A. Have ever seen someone running away from their answers to discovery at trial? These are used in conjunction with requests for admission. Rule 4:17-3. 8/22. Well-drafted interrogatory answers can put more money in your pocket. Defendants and their attorneys tend to use the same standard form interrogatories in all cases so these interrogatory examples should give you a good idea of what to expect. first. FOR PLAINTIFF UNITED STATES OF AMERICA: Carl Schnee UNITED STATES ATTORNEY FOR THE DISTRICT OF DELAWARE, By: _________________________________ Judith M. Kinney Assistant United States Attorney U.S. Attorney's Office 1201 Market Street, Suite 1100 Wilmington, DE 19801 (302) 573-6277 Delaware Bar No. So if you can pin down what the arguments will be, you will be in a much better position to structure your case effectively. Hurley v. The Atlantic City Police 6/2014. Except as provided in R. 4:17-1(b)(2), initial interrogatories shall be served by plaintiff as to each defendant within 40 days after service of that defendant's answer and each defendant shall serve initial interrogatories within said 40-day period. Why do they do it? DEJON WELCOME, CIEMON MOUZON. Visit our law office in Bergen County or give us a call at (201) 487-1199 to schedule an appointment. Complaint for Divorce (with children) Complaint for Divorce (without children) Certification of Insurance (filed with Complaint and Answer) Confidential Litigant Information Sheet (filed with Complaint and Answer) Answer and Counterclaim. Download Form . Separately for 1990 and each subsequent year through 1996, describe in detail and quantify each separate cost or expense, and all fees and other income Dentsply collected from third parties, relating to training or educating dentists. Rule 4:17-8. (b) It is permissible for interrogatories to include a request for a copy of a document. Art of Advocacy: Preparation of the Case Your landlord must respond to these requests under oath; they are then admissible in court if you need them. 3 0 obj IN THE COURT OF COMMON PLEAS EIGHTH JUDICIAL CIRCUIT GREENVILLE COUNTY, SOUTH CAROLINA RICHARD A. GORMAN, Plaintiff, VS. JOHN MONARCH, Defendant. 21. endstream endobj 31 0 obj <> endobj 32 0 obj <> endobj 33 0 obj <>stream 697 Valley Street, Suite 2d, Maplewood, NJ 07040 [created January 20, 2011] Page 3 of 6 6. Request for Records Inspection: this form must be completed and signed before the Division can release records. REV. 5. Amendments may be allowed thereafter only if the party seeking to amend certifies therein that the information requiring the amendment was not reasonably available or discoverable by the exercise of due diligence prior to the discovery end date. HWkon-b@@A(GwmQM3g'>/5HddI2/`*KI-?][/ !Yo Resource Family Information Form (Word form) CN: 10159. (We do too.) Browse Workers Compensation forms and publications below. "Shade guide" means any device used to match the color or shade of prefabricated artificial teeth to a patient's natural teeth for the specifications contained in a dentist's prescription for dentures or any other removable or fixed dental prosthetic device.